Small family — One letter sent by 3 to 9 people, copied or lightly reworded. One of 4 submissions in its group. See the letter, its submissions and topics.
In short: The comment documents specific local impacts in Central Oregon, including threats to the Bend Municipal Watershed and wildlife corridors in the Metolius Basin, and asserts that the agency's public comment process is inadequate due to the lack of public meetings and shortened comment periods.
Scored with own additions — A family member whose own text beyond the shared letter was scored and combined with the letter's score.
Scorecard
Each dimension is scored 0–3; the eight sum to the substance score out of 24.
- Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
- Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
- EA analysisEngages the agency's environmental analysis directly.
- Analytical gapIdentifies something the analysis fails to address.
- EvidenceBacks claims with specific facts, data, or research.
- RequestMakes a specific, actionable request of the agency.
- AlternativeProposes a different course of action.
- LegalCites statutes, regulations, or legal obligations.
How hard it is to set aside
A0 none: Counted, not answered.
Still open to the agency
- Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
- Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
- Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
- Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
- Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
- Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
- No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
- Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
- Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.
Topics
- Environmental Protection Biodiversity
- “protected wildlife habitat”
- “maintaining mule deer and elk migration corridors”
- “damage recreation areas, scenic views, and wildlife habitat”
- “Roadless forests represent some of the most intact, resilient ecosystems”
- Water Quality Quantity
- “ensured clean drinking water for 25 years”
- “More roads will also degrade drinking watersheds”
- “threaten water quality for fish species and the drinking water supply”
- “protecting the clean water”
- Governance Policy Process
- “abridged and inadequate public comment process”
- “zero public meetings, shortened comment periods”
- “disregard for the public input received during scoping”
- “undemocratic and deeply irresponsible”
- Climate Carbon Storage
- “reduce the carbon storage we need to combat climate change”
- “climate resilience”
- “erode forest resilience in the face of rapidly shifting wildfire regimes”
The comment
Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidence